INCOME TAX OFFICER, REWARI vs. A.N. ENTERPRISES, REWARI

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ITA 1202/DEL/2026Status: DisposedITAT Delhi29 June 20263 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal acknowledged divergent judicial opinions on bogus purchases and decided that a lumpsum addition of Rs.25 lakhs out of the total bogus purchases would be just and proper, without setting a precedent.

What were the facts?

The Assessing Officer disallowed the assessee's entire bogus purchases of Rs.7,03,35,200/-. The CIT(A)/NFAC deleted this disallowance. The revenue appealed this deletion.

What were the issues?

Whether the entire disallowance of bogus purchases was justified, and if not, what would be a fair addition.

Which sections of the Income-tax Act were involved?

Section 69C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: ‘G’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHANDRA

For Appellant: Ms. Sakshi Singla, CA
Hearing: 13.05.2026Pronounced: 13.05.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.1202/Del/2026 Assessment Year: 2021-22 Income Tax Officer, Vs. M/s. A.N. Enterprises, Rewari 83, Near Water Treatment Plant, Sector-3, Part-2, Rewari PAN: AAYFA0610Q (Appellant) (Respondent) Assessee by Ms. Sakshi Singla, CA Department by Sh. Choudhary N.C. Roy, Sr. DR Date of hearing 13.05.2026 Date of pronouncement 13.05.2026 ORDER PER SATBEER SINGH GODARA, JM This Revenue’s appeal for assessment year 2021-22, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1083380302(1), dated 07.12.2025 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

ITA No.1202/Del/2026

2.

Learned departmental representative vehemently argues during the course of hearing that the CIT(A)/NFAC has erred in law and on facts in deleting the Assessing Officer’s action disallowing the assessee’s entire bogus purchases of Rs.7,03,35,200/- u/s 69C sourced from Ms. Reena and M/s. Nativeroots Commtrade Pvt. Ltd. as no substantial documents have been brought on record regarding the above bogus purchases. 3. That being the clinching factual position, learned counsel appearing for both the parties could hardly dispute that various judicial precedents (2025) 173 taxmann.com 592 (Guj.) Ravjibhai Becharbhai Dhamelia vs. ACIT; (2024) 160 taxmann.com 110 (Bom) PCIT Vs. Hitesh Mody (HUF), (2024) 160 taxmann.com 93 (Del) PCIT Vs. Forum Sales (P) Ltd.; (2025) 172 taxmann.com 283 (Bom) PCIT Vs. Kanak Impex (India) Ltd; (2025) 178 taxmann.com 424 (Del. – Trib.) DCIT Vs. Kohinoor Foods Ltd.; and (2025) 177 taxmann.com 836 (Delhi-trib.) DCIT Vs. Tirupati Matsup (P.) Ltd. have recently decided the instant issue of bogus purchases with divergent opinions as well. It is thus deemed appropriate in the larger interest of justice that a lumpsum addition of Rs.25 lakhs in the assessee’s hands out of the total bogus purchases of

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ITA No.1202/Del/2026

Rs.7,03,35,200/-, would be just and proper with a rider that the same shall not be treated as a precedent. Necessary computation shall follow as per law. 4. This Revenue’s appeal is partly allowed. Order pronounced in the open court on 13th May, 2026 Sd/- Sd/- (NAVEEN CHANDRA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 29th June, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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